View source for NRC-2022-0158, Comment (18) of Jan Boudart on Palisades Nuclear Plant, Post-shutdown Decommissioning Activities Report (Psdar))

{{Adams
| number = ML23005A214
| issue date = 12/27/2022
| title = Comment (18) of Jan Boudart on Palisades Nuclear Plant, Post-shutdown Decommissioning Activities Report (Psdar))
| author name = Boudart J
| author affiliation = Nuclear Energy Information Service
| addressee name = 
| addressee affiliation = NRC/ADM
| docket = 05000255
| license number = 
| contact person = 
| case reference number = NRC-2022-0158, 87FR52598 00018
| document type = General FR Notice Comment Letter type:NRC
| page count = 1
}}

=Text=
{{#Wiki_filter:SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Marlayna Doell, Sarah Achten, Pam Buzdygon-Menefee, Mary Neely Comment (18)
Publication Date: 8/26/2022 Citation: 87 FR 52598
`From: Jan Boudart <janboudart1@gmail.com>
Sent: Tuesday, December 27, 2022 11:49 PM To: Stacy Schumann <Stacy.Schumann@nrc.gov>

==Subject:==
[External_Sender] Palisades Nuclear Plant, Docket ID NRC-2022-0158 December 27, 2022 Office of Administration ATTN: Program Management, Announcements and Editing Staff Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Via submission to Regulations.gov and cc to Stacy.Schumann@nrc.gov December 27, 2022 RE: Palisades Nuclear Plant, Docket ID NRC-2022-0158 (Comments on post-shutdown decommissioning activities report (PSDAR))

==Dear NRC Office of Administration:==

I hereby submit comments on the PSDAR and associated concerns related to the Palisades Nuclear Plant.
Part I.
I endorse and support the comments of Terry J. Lodge, esq..
As his comments made obvious, in spite of clear rules set out by the DOE regarding the Civil Nuclear Credit Program, Holtec Decommissioning International was for a second time lured into applying for a large payout from that program. Thus, Holtec should refund the money it used so far to decommission Palisades and refrain from decommissioning activities, and using decom money, until its CNC request is resolved.
Part II: Discrete Radioactive Particles, a snag to remediation of NPP sites I am concerned with the dust and shavings that escape during the dismantling of nuclear plant parts, specifically what the NRC is calling discrete radioactive particles (DRPs). Although DRPs will exist before dismantling takes place; the process has the potential to multiply them enormously. As Greg Chapman taught at the 2022, November 3rd NRC workshop meeting on Discreet Radioactive Particles: (I have modified and added to these bullet points)
* DRP monitoring must begin with initial operation of a nuclear power plant (NPP) and continued through decommissioning, dismantling and license termination.
* DRPs generated through decommissioning activities should be controlled at the source
* If a release to environment occurs, licensees should take corrective action to identify the extent of release, remediate as appropriate, and document surveys to support potential license termination reviews. The quicker the better to avoid secondary environmental transport
* DRPs are present in the environment and should be monitored and managed in all operational activities
* Neither license termination or decommissioning should proceed without strict guidance to prevent DRPS and to rid any site of DRPs before it is returned to public use.
At the Zion NPP the NRC, to its credit, refused to allow Zion Solutions to return the license to Constellation because, in spite of there being no violations to decom procedures, the site was not clean. The persistence of this problem is manifest in the fact that more than a year has passed and the problem of ridding Zion of DRPs has not been solved and license termination does not proceed.
Part III: Discrete Radioactive Particles, created in decom activities Greg Chapman gave examples of how DRPs are a product of normal decom activities. Here's his list which he says are only examples:
     *    "Neutron activated metal (legacy wearing particles, cuttings from reactor vessel (RV)/RV internals/rebar in bioshield, etc.)
     *    "Legacy fuel flea (spent fuel)
     *    "Neutron activated bioshield concrete (primarily Europium (Eu) isotopes)
     *    "Others, e.g., natural Thorium from welding/cutting, damaged sources, etc."
Part IV: Discrete Radioactive Particles, An Imminent health risk.
DRPs do not stay put. They are tagged at less than 300&#xb5;; so they are in dust and motes that are transferred when soil is disturbed and/or the wind picks them up. Reputedly, some of the Russian soldiers that moved into the Chernobyl exclusion zone got sick from the DRPs that were everywhere in the soil, air and water of thecontaminated area.
A. Examples from the Fukushima explosions.
For example, Fukushima hot particles (identified by their Cs 134/137 ratio) were found in Tokyo, 140 miles north, 10 years after the explosions: " microparticles rich in radioactive caesium that reached as far Tokyo, 225 km away." https://physicsworld.com/a/new-type-of-fallout-from-fukushima-daiichi-found-a-decade-after-nuclear-disaster/
And, according to Dr. Satoshi Utsunomiya of Japans Kyushu University, [We] discovered a new type of radioactive particle 3.9 km north northwest of the Fukushima Daiichi Nuclear Power Plant, which has the highest caesium-134 and caesium-137 activity yet documented in Fukushima, 105-106 Bq per particle, B. Rocky Flats National Wildlife Refuge harbors DRPs from the Cold War.
Author Kristin Iverson wrote There are breathable particles of plutonium out there in various hot spots and people need to know the kind of risks theyre taking if theyre hiking or biking out at the Rocky Flats National Wildlife Refuge. https://www.coloradodaily.com/2021/03/05/peace-train-rocky-flats-national-wildlife-refuge-is-too-risky-and-should-be-closed/
C. DRPs are hard to detect and linger in soil that might be farmed in the future.
Six inches of soil will absorb many of the hot particle radiation signals; thus, even with rad monitors, they can be very hard to detect and go unnoticed. When pipes and concrete from nuclear plants are buried the short- and long-lived activation isotopes may contaminate the soil undetected. If this soil is returned to nature, as at Rocky Flats, the wildlife and native plants will

suffer the effects of this radiation down through their generations. If the soil is remediated for farming, this effect will contaminate human food, and genetic damage can continue down through the human generations.
Part V: Conclusion DRPs have only recently made headlines as a threat to human health. They spread in soil, air and water. They are a universal product of nuclear activity, especially bomb testing and decommissioning and dismantling NPPs. Therefore, no longer can PSDARs be acceptable if they do not explain how the decom company is going to deal with hot particles. The following bullets are partially excerpted from the NRC's summary of Greg Chapman's comments on 2022, 11/03. (NRC Document dated 2022, Nov.
17: 

==SUMMARY==
OF NOVEMBER 3, 2022, HYBRID PUBLIC WORKSHOP ON DISCRETE RADIOACTIVE PARTICLES)
* The importance of DRP management from operations to decommissioning, need for controls and need to address DRPs sooner rather than later to prevent transport in the environment.
* If known to be an issue at decommissioning sites, licensees should address DRPs in planning documents, such as the license termination plan, as applicable. Licensees should not wait until the FSS (Final Status Survey) phase to address DRPs (as has happened at Palisades and Zion NPPs).
* The NRC will be developing guidance or communications related to DRPs in decommissioning in the future.
Thank you, Sincerely, Jan Boudart, board member, Nuclear Energy Information Service, NEIS.org}}